The Eleventh Circuit Court of Appeals has sided with Metropolitan Life Insurance Company (MetLife) in a case involving Stacy Hovan, a former commercial litigator who challenged the termination of her long-term disability benefits. The court affirmed the lower court’s decision, concluding that MetLife’s decision was not “wrong” under the Employee Retirement Income Security Act of 1974 (ERISA).
Background of the Case
Hovan, a former commercial litigator, was diagnosed with bipolar disorder in 2005. She began receiving long-term disability benefits from MetLife in June 2019 after ceasing work due to a mental health crisis. These benefits were provided through a plan offered by her former employer, Troutman Sanders LLP.
The core of the dispute revolves around MetLife’s decision to terminate these benefits, effective October 16, 2020. MetLife argued that Hovan no longer met the plan’s definition of “disabled” after her discharge from a partial hospitalization program at PeakView Behavioral Health.
The Plan’s Provisions
Under the ERISA plan, MetLife had discretionary authority to interpret the plan’s terms and determine eligibility for benefits. The plan defined “Own Occupation” for attorneys as the specialty in the practice of law in which they were engaged just prior to the disability. The plan also stipulated that benefits would end if the claimant failed to provide proof of continuing disability.
Key Events and Medical Evidence
Hovan’s benefits were initially approved based on reports from her psychiatrist, Dr. Michael Lara, who documented impaired judgment and other symptoms.
After her discharge from PeakView in October 2020, Hovan’s primary evidence of continued disability was therapy notes from sessions with Ms. Sherrie Stevens. While these notes showed fluctuations in mood and occasional reports of depression, mania, and anxiety, they did not indicate any occupational restrictions or cognitive impairments that would prevent Hovan from working as a commercial litigator. Ms. Stevens consistently recorded that Hovan’s “functional status” was “intact,” her affect was “appropriate,” and her cognition was “oriented/alert.”
MetLife also sought an independent review of Hovan’s medical records from Dr. Sarah Ghebrendrias, a psychiatrist. Dr. Ghebrendrias concluded that there was no evidence of limitations in Hovan’s status after her release from PeakView.
Hovan declined to provide additional evidence to MetLife, instructing them to proceed with the administrative appeal based on the existing record. MetLife then denied her appeal.
The Court’s Analysis: Applying the “Blankenship” Framework
The Eleventh Circuit employed the “Blankenship” framework, a six-step process used to determine the appropriate standard of review for ERISA cases. This framework determines whether the plan administrator’s decision was “wrong” and if the administrator had the discretion to make such decisions.
The court found that MetLife’s decision to terminate benefits was not “de novo wrong.” The court focused on the lack of evidence in Ms. Stevens’s therapy notes to demonstrate that Hovan was unable to perform her duties as a commercial litigator after her discharge from PeakView. The court noted that these notes did not identify occupational restrictions or cognitive impairments.
The court also addressed Hovan’s arguments. It rejected the claim that MetLife improperly required a treating provider to opine explicitly on her work capacity, stating that the burden was on Hovan to provide evidence of her continued disability. The court also dismissed the argument that MetLife relied too heavily on the medical file-reviewer’s opinion, emphasizing that the focus was on the insufficiency of the evidence Hovan provided.
The Ruling
Ultimately, the court affirmed the district court’s decision, upholding MetLife’s termination of Hovan’s disability benefits. The court concluded that Hovan did not meet her burden of demonstrating continuing disability, and the evidence she provided did not support her claim.